Implementation of QC Monitoring for CN Labeling Program

All manufacturers participating in the CN labeling program are required to have an Agricultural Marketing Service (AMS) or National Marine Fisheries Service (NMFS)-approved QC program by Oct. 1, 2009. Any product manufactured and labeled with the CN label after Oct. 1, 2009, without an approved QC program in place will be considered as produced in violation of CN labeling program requirements. The Food and Nutrition Service (FNS) in coordination with AMS and/or NMFS will issue violation notices to all CN program stakeholders.

The two attached 2008 notices to industry regarding these mandatory QC requirements included a tentative implementation date of spring 2009. Once it was established that the mandatory QC requirements would be implemented by Oct. 1, 2009, FNS began issuing temporary approvals for production through Oct. 1, 2009.

In order to obtain an FNS temporary or final approval for production after Oct. 1, 2009, manufacturers are required to attach the plant specific AMS or NMFS-approved QC coversheet to all CN label applications. Please refer to the Standard Operating Procedure for Submitting and Approving QC Programs for CN Labeled Products published at the CN labeling program website. CN label applications submitted after Oct. 1, 2009, without the AMS or NMFS documentation of QC approval will be returned to the manufacturer without review.

Manufacturers may request an AMS or NMFS letter of intent when they submit their QC program for review. However, the letter of intent is not acceptable documentation of an approved QC program. A label application submitted with a letter of intent after Oct. 1, 2009, will receive an “FNS DRAFT” at best. Manufacturers are not authorized to produce CN labeled products with an “FNS DRAFT” review stamp.

Manufacturers that maintain label applications with any of the following FNS approval stamps regardless of expiration date will be considered in violation of program requirements if the approved label is placed on product manufactured after Oct. 1, 2009, without an AMS or NMFS-approved QC program in place:

FNS approval stamps issued prior to Sept.1, 2007 (these final approvals expire on Sept.1, 2012):

As updates and resources for the CN labeling program become available, they will be posted at the CN labeling program website.

If you have any questions regarding the CN label application process, please do not hesitate to call the FNS-CN labeling program office at 703-305-2609. All questions regarding the QC program approval process should be directed to the AMS-CN labeling program operations office at 202-720-9939.

Sincerely, 

Cythia Long
Director
Child Nutrition Division

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